ceased to visit the islands after 1331, and only a few royal commissions to hear 
and determine specific causes are to be found. 57 From this it appears that the 
judicial needs of the islanders were being satisfied by the local royal courts in 
Jersey and in Guernsey. These two courts were holding pleas of the crown 
previous to 1331 —the distinction between pleas of the crown and other pleas 
having been obliterated. 08 This obliteration received recognition by the terms 
of the judicial power inserted in commissions to the wardens. 59 
Judicial authority consequently became concentrated in the respective bailiffs 
and jurats, but in view of the institutional parturition taking place within 
the realm itself, at some point a decision must have been necessary to determine 
which body should exercise appellate supervision. But the rationale of 
the decision which gave the King in Council such jurisdiction is wrapped in 
obscurity. It may have been a Norman institutional survival that appeals were 
taken to the King in Council, really in his ducal capacity. 60 It may have been 
the result of a recognition that the islands were outside the realm and that 
the King's writ did not run therein. 01 It may have resulted from abeyance of 
the error jurisdiction of the House of Lords. 62 
As to the date of conciliar assumption of this jurisdiction, it has been asserted 
that the Council became hearers of appeals from the Channel Islands 
at the end of the fifteenth or the beginning of the sixteenth century. 63 It has 
also been alleged that this Privy Council jurisdiction was usurped, that it 
originally belonged to the Council in Star Chamber. 64 At any rate, in 1495 it 
was necessary to issue a conciliar order restricting appeals "au Roy et i Con- 
Palmer 54); Anonymous (1 Ventris 357); Rex 
v. Overton (1 Sid. 386). 
57 Le Patourel, op. cit., 66. 
58 Ibid. 
™Ibid., 128. 
60 See Extentes of Guernsey, 147, 150; Le 
Patourel, op. cit., 29; cf. Macqueen, op. cit., 
682-85. 
61 By analogy to the King's Bench practice; see 
supra, p. 10. 
62 Macqueen, op. cit., 686; 2 Anson, op. cit., 
Part 11, 321; Keith, op. cit., 305; cf. Palgrave, 
op. cit., Ill; Plucknett, Concise History of the 
Common Law (3d ed., 1940), 185. The nadir 
of interpretation is attained by Beauchamp 
(Jurisprudence of the Privy Council [1891], 
8-9). Generally on the decline of the error jurisdiction 
of the House of Lords see Hale, Jurisdiction 
of the House of Lords (1796), v—viii; 
Maitland, op. cit., 245-46; Petit-Dutaillis and 
Lefebure, Studies and Notes Supplementary to 
Stubb's Constitutional History 111 (1929), 442; 
Pickthorn, Early Tudor Government, Henry 
VII (1934), 117-18; Beven, Appellate Jurisdiction 
of the House of Lords, 17 LQR 163-64. 
03 Haver, op. cit., in 39 Bibliotheque de l'Ecole 
des Chartes, 53; Macqueen, op. cit., 686; cf. 
Percy, The Privy Council under the Tudors 
(1907), 7; Dicey, The Privy Council (1887), 
90. 
64 See Hudson, A Treatise of the Court of Star 
Chamber, 2 Collectanea Juridica (1792), 62. 
But this jurisdictional assertion is not borne out 
by the records. For Star Chamber original jurisdiction 
over the Channel Islands see 1 List of 
Proceedings in the Court of Star Chamber Preserved 
in the Public Record Office, 1485-1558; 
13 P.R.O. Lists and Indexes, 36, 53, 82, 85, 
174, 184, 197, 262. On earlier seventeenthcentury 
objections to Star Chamber jurisdiction 
over the Channel Islands see All Souls College 
MS, 204/5. As to the distinction between the 
Star Chamber and the Privy Council under 
Henry VII see Schofield, A Study of the Court 
of Star Chamber (1900), 26-29.